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ESTATE OF WALLACE v. COMMISSIONER

Docket No. 22960-88.

95 T.C. 525 (1990)

ESTATE OF GERALD L. WALLACE, DECEASED, CELIA A. WALLACE, EXECUTRIX, AND CELIA A. WALLACE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 14, 1990.

Attorney(s) appearing for the Case

Roland J. Mestayer, Jr., G. Tomas Rhodus, and Clark S. Willingham, for the petitioners.

Helen C.T. Smith, for the respondent.

SCOTT, Judge:

Respondent determined deficiencies in petitioners' income tax for the calendar years 1980 and 1983 in the amounts of $303,129 and $566,236, respectively. Dr. Gerald L. Wallace (Dr. Wallace) died on November 13, 1986, prior to the issuance of the notice of deficiency in this case. However, since the years here involved are 1980 and 1983, we will hereinafter refer to Dr. and Mrs. Wallace as petitioners. Some of the issues raised by the pleadings...

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